U.	S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Petition for Exemption, requesting relief from the 

FAA Modernization and Reform Act of 2012, 

Public Law 112-95 FEB. 14, 2012, Section 333. 

Whereas, Great River Information Technologies LLC seeks relief 

from airworthiness certification requirements from the above 

mentioned regulations. 

Great River Information Technologies is a multimedia solutions 

provider with the express purpose of providing aerial videography 

for realtors, crop inspection for farmers, and surveys for 

construction companies. We are requesting to use a UAS for aerial 

data collection.

Great River Information Technologies is represented by Robert 

Malli, Software Engineer, U.S. Army Veteran, DC Area Drone 

User Group member and current Academy of Model Aeronautics

member. Mr. Malli has over 20 years of software development 

experience and four years of UAS flying experience.

I. Contact Information

Robert	Malli

12602	Misty	Creek	Lane

Fairfax,	VA	22033

703-538-6796

Robert@greatriverit.com
II. The Specific Sections of Title 14 of the Code of 

Federal Regulations From Which Great River 

Information TechnologiesRequests Exemption are:

14	CFR	21; 14	C.F.R.	45.23(b);

1 4	CFR	61.113	(a)	&	(b);

14	C.F.R.	91,	et	seq.;

14	CFR	407	(a)	(1);

14	CFR	409	(a)	(2);	and,

14	CFR	417	(a)	&	(b)

Great River Information Technologies seeks this exemption under 

the guidelines of Section333 specifically as it relates to the 

Agriculture Industry in the greater Midwest area under the small 

UAS rule. The main operating focus will be in the state of Iowa. A 

small portion of business will be offered in the real estate industry 

in Virginia area while most of the business focus will be 

concentrated in the Midwest. We believe that we have put together 

a program as responsible operators of an UAS that will stand as an 

exemplary model on whom many others entering the market will 

emulate.

Under the terms of this exemption, it is our intention to safely fly 

an UAS, specifically a DJI Phantom 3 and DJI S900. Both UAS 

weigh less than 15 pounds. Additionally these drone vehicles 

maintain a FPV connectivity utilizing a Lightbridge connection to 

an iPad Mini 3 HD field monitor, allowing the pilot to see exactly 

what the Drone camera sees. Additionally, our pilot apps logs all 

flight data and ensures the UAS is in a “safe to fly” zone to record 

a safe and reasonable flight.

As air safety is of paramount importance, Great River Information 

Technologies has developed a highly structured safety flight 
manual for our pilot as well as observer. As recent as the new 

proposed FAA regulation released as of February of 2015, Great 

River Information Technologies intends to operate well within the 

most stringent proposal required to operate an unmanned aircraft in 

the National Airspace System (NAS). We are prepared to attend 

any required course of study, participate in flight evaluation and 

pay any required fee(s) that may be instituted. We have many 

hundreds of combined hours of safe flying in the recreational 

mode.

III. Public Interest

We firmly believe that granting this exemption will allow for 

expanded precision agriculture application development, such as 

crop health monitoring, irrigation monitoring, fertilizer 

management, and herd management. In regards to the real estate 

industry, many properties are "hidden" behind walls and 

landscaping, resulting in diminished "curb appeal". Providing this 

relief would eliminate these problems and lead to increased 

commerce for both buyers, sellers, government taxation agencies, 

real estate affiliated companies, (title, escrow, notary), construction 

industry and home improvement businesses who rely on a thriving 

real estate market. 

Additionally UAV's provide for property inspections including 

roof and chimney that can assist in identifying hard to observe 

defects in manufacturing and installation.

Currently, precision agriculture and real estate aerial 

videography/photography relies primarily on the use of larger 

aircraft running on combustible fuel. Posing potential risk to the 

public. Granting Great River Information Technologies’, request 

for exemption will reduce current risk levels and thereby enhance 

safety.
Lastly, aerial videography provides the viewer with safe access to 

the property vicinity via a virtual view eliminating needless 

driving to determine how close a property is to a freeway, school, 

beach or nearby unsightly development. This in turn reduces 

exhaust emissions and air pollution since our UAV's utilize 

battery power and have no negative impact on the environment.

IV. Reasons Why Great River Information Technologies' 

Exemption Will Not Adversely Affect Safety 

Great River Information Technologies’, exemption will not 

adversely affect safety. Quite to the contrary, for the reasons 

stated permitting us, to log more flight time in FAA controlled 

airspace, with communication with the FAA, will allow us to 

contribute to the innovation and implementation of new and 

novel, as of yet undiscovered safety protocols and applications

for development in cooperation with the FAA. In addition I, 

Robert Malli, submit Great River Information Technologies’ 

Policy & Procdures Manual. (Appendix A)

V. A Summary The FAA May Publish in the Federal 

Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, 

Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, 

sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 

91.203(a)(1). The size, weight and enclosed operational area 

of our, Great River Information Technologies', UAS permits 

exemption from Part 21 because our UAS meets (and 

exceeds) an equivalent level of safety pursuant to Section 
333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and 

Section 333 of the Reform Act. Both pieces of legislation 

permit the FAA to exempt UAS's from the airworthiness 

certificate requirement in consideration of the weight, 

size, speed, maneuverability and proximity to areas 

such as airports and dense populations. Great River 

Information Technologies', current and projected UAS's meet 

or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft 

without an airworthiness certificate. As no such certificate 

will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in 

the aircraft. As there are no on board pilots or passengers, 

and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved 

by maintaining a safety/flight manual delineating areas of 

where safety can be defined. 10 The FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is 

inapplicable insofar as my UAS utilizes electronic global 

positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of 

civil aircraft certifications and registrations. They are 

inapplicable for the same reasons described above. The 

equivalent level of safety will be achieved by maintaining 
any such required certifications and registrations by Great 

River Information Technologies.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be 

marked according to certain specifications. Our UAS are, by 

definition, unmanned. They therefore do not have a cabin, 

cockpit or pilot station on which to mark certain words or 

phrases. Further, two-inch lettering is difficult to place on 

such small aircraft with dimensions smaller that minimal 

lettering requirement. Regardless, I will mark its UASs in the 

largest possible lettering by placing the word 

“EXPERIMENTAL” on its fuselage as required by 14 C.F.R. 

§45.29 (f) so that I the pilot, or anyone assisting me as a 

spotter with the UAV will see the markings. The FAA has 

previously issued exemptions to this regulation through 

Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: 

PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are 

limited to non -commercial operations. Great River 

Information Technologies can achieve an equivalent level of 

safety as achieved by current Regulations because my UAS 

does not carry any pilots or passengers. Further, while 

helpful, a pilot license will not ensure remote control piloting 

skills. The risks attended to the operation of our UAS is far 

less than the risk levels inherent in the commercial activities 

outlined in 14 C.F.R. § 61, et seq. Thus, allowing Great River 

Information Technologies to operate our UAS meet and 

exceed current safety levels in relation to 14 C.F.R. §61.113 

(a) & (b).
D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation 

of civil aircraft. It allows helicopters to be operated at lower 

altitudes in certain conditions. Our UAS will never operate at 

an altitude greater than 200 AGL; safely below the standard 

of 400 AGL. Great River Information Technologies will 

however operate our UAS in safe areas away from public and 

traffic, providing a level of safety at least equivalent to or 

below those in relation to minimum safe altitudes. Given the 

size, weight, maneuverability and speed of my UAS, an 

equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): 

Maintenance Inspections

The above-cited Regulations require, amongst other things, 

aircraft owners and operators to “have [the] aircraft inspected 

as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of 

this section, have discrepancies repaired as prescribed in part 

43 of this chapter. . . .”

These Regulations only apply to aircraft with an 

airworthiness certificate. They will not, therefore, apply to 

Great River Information Technologies’, UAS. However, as a 

safety precaution we inspect our UAS before and after each 

flight.

A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, 

Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled 

Airworthiness Certificates, sets forth requirements for procurement 

of necessary airworthiness certificates in relation to FAR § 

91.203(a)(1). The size, weight and enclosed operational area of our
UAS permits exemption from Part 21 because Great River 

Information Technologies’ UAS meets an equivalent level of 

safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and 

Section 333 of the Reform Act. Both pieces of legislation permit 

the FAA to exempt UAS's from the airworthiness certificate 

requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense 

populations. Our UAS meets or exceeds each of the elements. 14 

C.F.R. 91.7(a) prohibits the operation of an aircraft without an 

airworthiness certificate. As no such certificate will be applicable 

in the form contemplated by the FARs, this Regulation is 

inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight 

manual in the aircraft. As there are no pilots or passengers, and 

given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a 

manual. The FAA has previously issued exemptions to this 

regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, maintenance program that involves regular 

software updates and curative measures for any damaged 

hardware. Therefore, an equivalent level of safety will be achieved.

VI. In summary, Great River Information Technologies 

seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § § 61.113 

(a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 

91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 

91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 

C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 

(a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & 

(b) to commercially operate Great River Information 
Technologies’ small unmanned vehicle/lightweight unmanned 

aircraft vehicle in precision agriculture and real estate operations, 

and to develop applications in regards to these industries in the 

Midwest and Virginia. Currently, precision agriculture and real 

estate aerial videography/photography relies primarily on the use 

of larger aircraft running on combustible fuel. Posing potential risk 

to the public. Granting Great River Information Technologies’ 

request for exemption will reduce current risk levels and thereby 

enhance safety.

Great River Information Technologies is dedicated and committed 

to promoting the safe use of UAV's in the United States. We look 

forward to working with the FAA and promoting this new 

industry.

Along with this Petition we are respectfully submitting the 

following support documents.

Exhibit A: Presents our proposed safety guidelines, pre-flight 

checklist, and their implementation incorporated into our GREAT 

RIVER INFORMATION TECHNOLOGIES POLICY & 

PROCEDURES manual.

Exhibit B: Presents GREAT RIVER INFORMATION 

TECHNOLOGIES PERMISSION/WAIVER document.